MS4 PROGRAM AUDITS: MUNICIPALITIES PERSPECTIVE

Transcription

1 MS4 PROGRAM AUDITS: MUNICIPALITIES PERSPECTIVE Maine Stormwater Conference October 24, 2017 Robyn Saunders, CCSWCD Program Director

2 Overview Why CCSWCD can provide municipal perspective? What CCSWCD s observations have been? Questions?

3 Background Cumberland County Soil & Water Conservation District (CCSWCD) Facilitates Interlocal Stormwater Working Group (ISWG) Implements 2 of the 6 Minimum Control Measures (MCMs) MCM 1 Education & Outreach MCM 2 Public Participation Assists during MS4 audits

4 Background 11 of 14 ISWG MS4s audited CCSWCD attended 10 of 11 audits Audits led by both EPA and DEP At a minimum, CCSWCD reports on MCMs 1&2 compliance Roles vary by community Usually part of Audit Team Before After

5 Minimum Control Measure #1 Public Education & Outreach: Educate the public and municipal staff/officials and legislators about polluted runoff and how to reduce pollution.

6 What is Stormwater? Precipitation, or snow melt, that flows over the land...

7 Why a Stormwater Permit? plus anything that is carried with it.

8 Common Pollutants Soil, sand, and sediment Chemicals Pet waste Salt Trash and debris

9 Minimum Control Measure #1 Public Education & Outreach: Educate the public and municipal staff and officials about polluted runoff and how to reduce pollution. FEEDBACK ON TRAINING (MCM 1&6) Include an agenda and evaluation mechanism Maintain documentation Print and sign all participants names

10 Minimum Control Measure #2 Public Participation: Provide the public an opportunity to participate in each municipalities stormwater program.

11 WANTED: Volunteers Runners Walkers Sponsors* April 21, 2018 *To benefit CCSWCD s CONNECT Program, which is education to school aged children in Windham and throughout Cumberland County

12 Minimum Control Measure #2 Public Participation: Provide the public an opportunity to participate in each municipalities stormwater program. FEEDBACK ON EVENTS (MCM 2) Maintain a list of active participants Availability of permit documents on website Report on additional activities Stream cleanups Household hazardous waste days

13 CCSWCD Involvement: Audit Process ISWG membership includes: Attendance at desktop review in the morning A customized report for your MS4 involvement in MCM 1&2 CCSWCD services can include: BEFORE: Mock audit (if/when time allows) & Interdepartmental meetings DURING: Function as a scribe for field inspection team(s) MCM 3 Group reviewing maps followed by field inspection MCM 4&5 Group reviewing construction permits before field inspection MCM 6 Group touring all municipal facilities and operations AFTER: Correspondence with DEP/EPA

14 Minimum Control Measure #3 Illicit Discharge Detection & Elimination: Identify, investigate and eliminate sources of pollution. Carry out long term maintenance and mapping of all stormwater infrastructure.

15 Minimum Control Measure #3 IDDE: Sources of pollution

16 Minimum Control Measure #3 IDDE: MOST COMMON source of pollution

17 Minimum Control Measure #3 IDDE: Long term maintenance and mapping of stormwater infrastructure KEEP IT CURRENT! DATE OF LAST UPDATE!! PAPER VS. WEB ENABLED MAPS?

18 Minimum Control Measure #3 IDDE: Long term maintenance and mapping of stormwater infrastructure EPA returned 6 months later to collect samples

19 Minimum Control Measure #3 IDDE: New Outfalls No pipe or culvert. Is this an outfall?

20 Minimum Control Measure #3 IDDE: New Outfalls

21 Minimum Control Measure #3 IDDE: New Outfalls

22 Minimum Control Measure #3 IDDE: Identify, investigate and eliminate sources of pollution. Carry out long term maintenance and mapping of all stormwater infrastructure. FEEDBACK ON IDDE (MCM 3) Maintaining current maps and documentation Investigating steady dry weather flow Following up on: Illicit discharge investigations Dry weather flow observations Non stormwater discharge ordinance!!! Understanding spill response procedures (also MCM 6) Knowing the effective date of Non Stormwater Discharge Ordinance

23 Minimum Control Measure #4 Construction Site Runoff Control: Ensure that construction on both public and private property does not impact water resources.

24 Minimum Control Measure #4 Construction Site Runoff Control: Comply with Chapter 500/Maine Construction General Permit requirements.

25 Minimum Control Measure #4 Construction Site Runoff Control: Comply with Ch 500/Maine CGP requirements.

26 Minimum Control Measure #4 Construction Site Runoff Control: Ensure that construction on both public and private property does not impact water resources. FEEDBACK ON IDDE (MCM 4) Following up on and documenting: Weekly inspections Corrective Actions Keeping documents on site Submitting documents to MS4

27 Minimum Control Measure #5 Stormwater Management after Construction: Implement new development and redevelopment stormwater ordinances. Encourage developers to use techniques to reduce impact of development on water resources.

28 Minimum Control Measure #5 Stormwater Management after Construction: Implement new development and redevelopment stormwater ordinances. Encourage developers to use techniques to reduce impact of development on water resources. FEEDBACK ON IDDE (MCM 5) Following up on and documenting: Annual inspections Maintenance Corrective Actions Submitting documents to MS4

29 Minimum Control Measure #6 Good Housekeeping & Pollution Prevention: Prevent pollution from municipal operations and facilities. Educate municipal staff about practices to reduce polluted runoff.

30 Minimum Control Measure #6 Good Housekeeping & Pollution Prevention: Vehicle washing operations Where does it discharge? Beyond the catch basin Vegetated buffer? Point source? What are the BMPs? Is the location in your SWPPP? Inspected and/or sampled quarterly Washing versus rinsing

31 Minimum Control Measure #6 GH&P2: Around the yard Runoff no longer sheet flow

32 Minimum Control Measure #6 Looking Upgradient Looking Downgradient

33 Minimum Control Measure #6 Good Housekeeping & Pollution Prevention: Waste management What are the BMPs? All facilities DPW Municipal campus Schools Ball fields Transfer Stations SWPPP requirements

34 Minimum Control Measure #6 Good Housekeeping & Pollution Prevention: Other regulatory program requirements SPCC considerations Check volume threshold(s) Confirm secondary containment Include all non rolling stock CCSWCD also recommends EPCRA reporting Clean Air Act permitting Hazardous/Universal Waste management LABEL MISSING!

35 Minimum Control Measure #6 Good Housekeeping & Pollution Prevention: Prevent pollution from municipal operations and facilities. Educate municipal staff about practices to reduce polluted runoff. FEEDBACK ON IDDE (MCM 6) Keep SWPPPs current Keep O&M Plans current Keep documents for all corrective actions

36 Administrative Issues FEEDBACK ON ADMIN Interconnections with other MS4s Interactions with other NPDES Permittees Railroads Industrial facilities Highest priority watersheds

37 Questions?